11/20/2013

Please send your questions or comments about the Consumer Financial Protection Bureau's final rule for integrated mortgage disclosures to respacomments@alta.org. We will post answers and analysis to the final rule and forms here on our blog. We encourage title professionals to follow the blog as we will continue to provide analysis and information about implementing the new mortgage disclosures. The CFPB set an effective date of Aug. 1, 2015 for the industry to begin using the new disclosures.

Here are links to the final rule, Loan Estimate and Closing Disclosure:

The requirement to show amounts being deposited in escrow by the RE Broker that are in excess of the Real Estate Broker’s commission is not mentioned in the new CFPB rules. Currently that amount shows on the HUD on line 507 with a notation ‘disbursed as proceeds’. Can we clarify whether we will be required to disclose the RE Broker’s deposit of Earnest Money back into the Escrow on the CFPB Disclosure?

Perhaps I'm missing something in the new closing disclosure, but where does the privacy of information for both the buyer and the seller come into play? Also, I see no signature lines for the seller in the example closing disclosure.